Legal Opinion

Piggly Wiggly Corp. v. Commissioner

United States Board of Tax Appeals

Decided June 20, 1933No. Docket Nos. 25126, 43860Published

1. Held, the money which petitioner's president invested in stock of a licensee corporation in 1922 and, which, while so invested, was lost through embezzlement and conversion by said president, was a loss sustained in the prosecution of its regular business in 1922. 2, Held, under the facts shown, the several items which entered into a judgment balance which a Federal court found was due the taxpayer from its president, on account of overdrafts and unlawful withdrawals of…

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1. Held, the money which petitioner's president invested in stock of a licensee corporation in 1922 and, which, while so invested, was lost through embezzlement and conversion by said president, was a loss sustained in the prosecution of its regular business in 1922. 2, Held, under the facts shown, the several items which entered into a judgment balance which a Federal court found was due the taxpayer from its president, on account of overdrafts and unlawful withdrawals of its funds made by him in conducting its business, were lost to it respectively, as and when the various withdrawals and…

1Opinion of the Court

PIGGLY WIGGLY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Piggly Wiggly Corp. v. Commissioner

Docket Nos. 25126, 43860.

United States Board of Tax Appeals

28 B.T.A. 412; 1933 BTA LEXIS 1119;

June 20, 1933, Promulgated

1. Held, the money which petitioner's president invested in stock of a licensee corporation in 1922 and, which, while so invested, was lost through embezzlement and conversion by said president, was a loss sustained in the prosecution of its regular business in 1922.

2, Held, under the facts shown, the several items which entered into a judgment balance…

2Cases cited1 opinion

  1. Piggly Wiggly Corp. v. CommissionerUnited States Board of Tax Appeals · 1933

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